2023-005 – Procurement, Suspension & Debarment – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Federal Award Number: P425F201298 Award Year: 2022-23 Criteria – Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition/context – A sample of 4 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the 20 transactions that exceeded the micropurchase threshold of $10,000. For all four of the expenditures the University did not obtain the required rate quotations; per the University’s documented policy two quotes should have been obtained or have documentation supporting their conclusion to sole source the purchases. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and open competition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur. Repeat finding – Yes, 2022-006 Recommendation – We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University’s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. Views of responsible officials and planned corrective actions – The University puts measures in place to guarantee that every employee who makes federal purchases on the University's behalf is aware of the documented procurement policy that complies with 2 CFR Part 200. The University will formalize its code of conduct, which addresses conflicts of interest and sets performance standards for staff members who choose, award, and manage contracts.
Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326 (the Uniform Guidance) and use their own documented procurement procedures, which reflect applicable State and local laws and regulations provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Internal controls should be designed to ensure compliance with these federal requirements.Additionally, contracts involving federal funds must include certain provisions of Appendix II part 200. Condition: The Child Nutrition Program is administered for the School Board by the CNP department. The Department’s purchase of produce products was not subjected to bidding or other means of competitive solicitation in accordance with the Unform Guidance. Additionally, the contracts with vendors do not include the provisions contained in Appendix II part 200. Universe/ Population: Food purchases subject to the procurement regulations totaled approximately $1,000,000, among 5 vendors, of which 4 contracts totaling $800,000 were subject to audit. Of the 4 audited, 1 contract with purchases totaling $120,000 for the fiscal year was found to be non-compliant. Effect: The School Board may be non-compliant with the Uniform Guidance with respect to this contract for produce products. Cause: A shortage of suppliers in the geographic area may have led to the decision to forego the pricing and/or bidding process. Recommendation: Pricing, bidding or other forms of solicitation allowed by the Uniform Guidance should be conducted by the School Board’s Child Nutrition Department. Contracts should be standardized to include the language and provisions of Appendix II part 200. View of Responsible Official and Corrective Action Plan: The Child Nutrition Supervisor acknowledges the finding regarding the purchase of produce products for SY 2022-23. There is only one regional produce distributor that successfully delivers to the Franklin Parish area with accurate invoices and timely deliveries based on past history. Due to staff changes and re-assignment of essential job functions, the produce bid was overlooked for this this year only. Moving forward, the CNP Supervisor bas established a procurement schedule for developing and revising necessary formal bids in compliance with Federal and State requirements and all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition Program experienced multiple shortages of canned and frozen vegetables and fruits. This made it essential to fill in with fresh produce to meet meal pattern requirements. This created a marked increase in the cost of the fresh produce available to us and increased our reliance on fresh produce.
Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326 (the Uniform Guidance) and use their own documented procurement procedures, which reflect applicable State and local laws and regulations provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Internal controls should be designed to ensure compliance with these federal requirements.Additionally, contracts involving federal funds must include certain provisions of Appendix II part 200. Condition: The Child Nutrition Program is administered for the School Board by the CNP department. The Department’s purchase of produce products was not subjected to bidding or other means of competitive solicitation in accordance with the Unform Guidance. Additionally, the contracts with vendors do not include the provisions contained in Appendix II part 200. Universe/ Population: Food purchases subject to the procurement regulations totaled approximately $1,000,000, among 5 vendors, of which 4 contracts totaling $800,000 were subject to audit. Of the 4 audited, 1 contract with purchases totaling $120,000 for the fiscal year was found to be non-compliant. Effect: The School Board may be non-compliant with the Uniform Guidance with respect to this contract for produce products. Cause: A shortage of suppliers in the geographic area may have led to the decision to forego the pricing and/or bidding process. Recommendation: Pricing, bidding or other forms of solicitation allowed by the Uniform Guidance should be conducted by the School Board’s Child Nutrition Department. Contracts should be standardized to include the language and provisions of Appendix II part 200. View of Responsible Official and Corrective Action Plan: The Child Nutrition Supervisor acknowledges the finding regarding the purchase of produce products for SY 2022-23. There is only one regional produce distributor that successfully delivers to the Franklin Parish area with accurate invoices and timely deliveries based on past history. Due to staff changes and re-assignment of essential job functions, the produce bid was overlooked for this this year only. Moving forward, the CNP Supervisor bas established a procurement schedule for developing and revising necessary formal bids in compliance with Federal and State requirements and all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition Program experienced multiple shortages of canned and frozen vegetables and fruits. This made it essential to fill in with fresh produce to meet meal pattern requirements. This created a marked increase in the cost of the fresh produce available to us and increased our reliance on fresh produce.
Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326 (the Uniform Guidance) and use their own documented procurement procedures, which reflect applicable State and local laws and regulations provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Internal controls should be designed to ensure compliance with these federal requirements.Additionally, contracts involving federal funds must include certain provisions of Appendix II part 200. Condition: The Child Nutrition Program is administered for the School Board by the CNP department. The Department’s purchase of produce products was not subjected to bidding or other means of competitive solicitation in accordance with the Unform Guidance. Additionally, the contracts with vendors do not include the provisions contained in Appendix II part 200. Universe/ Population: Food purchases subject to the procurement regulations totaled approximately $1,000,000, among 5 vendors, of which 4 contracts totaling $800,000 were subject to audit. Of the 4 audited, 1 contract with purchases totaling $120,000 for the fiscal year was found to be non-compliant. Effect: The School Board may be non-compliant with the Uniform Guidance with respect to this contract for produce products. Cause: A shortage of suppliers in the geographic area may have led to the decision to forego the pricing and/or bidding process. Recommendation: Pricing, bidding or other forms of solicitation allowed by the Uniform Guidance should be conducted by the School Board’s Child Nutrition Department. Contracts should be standardized to include the language and provisions of Appendix II part 200. View of Responsible Official and Corrective Action Plan: The Child Nutrition Supervisor acknowledges the finding regarding the purchase of produce products for SY 2022-23. There is only one regional produce distributor that successfully delivers to the Franklin Parish area with accurate invoices and timely deliveries based on past history. Due to staff changes and re-assignment of essential job functions, the produce bid was overlooked for this this year only. Moving forward, the CNP Supervisor bas established a procurement schedule for developing and revising necessary formal bids in compliance with Federal and State requirements and all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition Program experienced multiple shortages of canned and frozen vegetables and fruits. This made it essential to fill in with fresh produce to meet meal pattern requirements. This created a marked increase in the cost of the fresh produce available to us and increased our reliance on fresh produce.
Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326 (the Uniform Guidance) and use their own documented procurement procedures, which reflect applicable State and local laws and regulations provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Internal controls should be designed to ensure compliance with these federal requirements.Additionally, contracts involving federal funds must include certain provisions of Appendix II part 200. Condition: The Child Nutrition Program is administered for the School Board by the CNP department. The Department’s purchase of produce products was not subjected to bidding or other means of competitive solicitation in accordance with the Unform Guidance. Additionally, the contracts with vendors do not include the provisions contained in Appendix II part 200. Universe/ Population: Food purchases subject to the procurement regulations totaled approximately $1,000,000, among 5 vendors, of which 4 contracts totaling $800,000 were subject to audit. Of the 4 audited, 1 contract with purchases totaling $120,000 for the fiscal year was found to be non-compliant. Effect: The School Board may be non-compliant with the Uniform Guidance with respect to this contract for produce products. Cause: A shortage of suppliers in the geographic area may have led to the decision to forego the pricing and/or bidding process. Recommendation: Pricing, bidding or other forms of solicitation allowed by the Uniform Guidance should be conducted by the School Board’s Child Nutrition Department. Contracts should be standardized to include the language and provisions of Appendix II part 200. View of Responsible Official and Corrective Action Plan: The Child Nutrition Supervisor acknowledges the finding regarding the purchase of produce products for SY 2022-23. There is only one regional produce distributor that successfully delivers to the Franklin Parish area with accurate invoices and timely deliveries based on past history. Due to staff changes and re-assignment of essential job functions, the produce bid was overlooked for this this year only. Moving forward, the CNP Supervisor bas established a procurement schedule for developing and revising necessary formal bids in compliance with Federal and State requirements and all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition Program experienced multiple shortages of canned and frozen vegetables and fruits. This made it essential to fill in with fresh produce to meet meal pattern requirements. This created a marked increase in the cost of the fresh produce available to us and increased our reliance on fresh produce.
Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department of the Treasury, Coronavirus State and Local Fiscal Recovery Fund Federal Award Identification Number and Year - SLFRP2024-2001 Pass-through Entity - Not applicable Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-002 Criteria - The City should ensure there is a process in place, prior to entering contracts with subrecipients, to verify that such subrecipients are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. Condition - We noted during testing that the City had unintentionally omitted a subrecipient from its search to ensure that the subrecipient was not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - From July 1, 2022 through June 30, 2023, any subrecipient with which the City entered into a contract using federal award funds should have been verified as not being suspended, debarred, or otherwise excluded pursuant to 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. We selected three subrecipients for testing, and one lacked any verification. However, based on our testing, we noted that the one subrecipient was not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300, thereby creating no questioned costs. Cause and Effect - The City is required to verify that any subrecipient with which it plans to enter into a contract using federal award funds is not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. The City did not complete this requirement due to timing of final approval of the subrecipient pass-through funds. Recommendation - We recommend that an additional internal control be put in place to ensure the dual verification of subrecipients occurs. Views of Responsible Officials and Corrective Action Plan - Procedures have already been put into place to ensure that each new contractor is not on the federal list of suspended and/or debarred contractors. Furthermore, all vendors previously paid have been searched for in the federal list, and none were suspended and/or debarred.
Federal agency: U.S. Department of Agriculture Federal program title: Special Supplemental Nutrition Program for Women, Infants, and Children Assistance Listing Number: 10.557 Pass-Through Agency: Iowa Department of Public Health, Division of Family and Community Health Pass-Through Numbers: 5883AO31 and 5881AO90E Award Period: October 1, 2017 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award contains various requirements for procurements made under federal awards. §200.318 requires a procurement policy be in place with specific requirements. §200.320 specifies the methods of procurement to be followed, including micropurchases,small purchases, sealed bids, competitive proposals, and noncompetitive proposals. Each procurement method has a threshold where quotes or bids are required to be obtained. Condition: During our testing, we noted one purchase over the micro-purchase threshold which did not have quotes as required. Context: During our testing, we noted one vendor tested over the micro purchase threshold did not have quotes obtained as required. Cause: The Medical Center contracted with the vendor who has previously done projects and remodeling for the facility to ensure the project was completed consistently with the rest of the building. As a result, the Medical Center did not obtain a second quote for the project. Effect: The Medical Center is not in compliance with the requirements of 2 CFR Part 200 §200.320. Recommendation: We recommend the Medical Center obtain quotes or bids as necessary for purchases that exceed the micro-purchase threshold. Additionally, we recommend the Medical Center maintain documentation of all quotes and bids to support the vendor chosen. In situations where there is an alternative method utilized, we recommend clearly documenting that process to ensure compliance.
Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.320 and 200.318(i); a non-federal entity must have procedures that document the rationale for the method of procurement, selection of the contract type, basis for contractor selection, and the basis for the contract price. In addition, Uniform Grant Guidance (2 CFR 20.303) requires nonfederal entities receiving Federal awards establish and maintain controls designed to reasonable ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing of the procurement process, we noted that college was not in compliance with the federal procurement regulations. Questioned costs: None Context: In our sample of three procurement transactions, one transaction did not have the required procurement documentation. Cause: The College had an existing contract with a vendor and thought the transaction was covered under the original procurement. Effect: The College is not in compliance with procurement requirements to properly document the procurement rationale for the method of procurement. Repeat Finding: No Recommendation: We recommend the College revise their processes to establish procedures that will ensure procurement policies are properly followed and documented for all general disbursements paid for by federal funds. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10555 Federal Award Program Year: July 1, 2022 – July 30, 2023 Pass-Through Agency: Arizona Department of Education Pass-Through Number: 07-84-09-001 Type of Finding: Other matter Compliance Requirement: Procurement and Suspension and Debarment Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. Condition: The School’s policy governing procurement requirements for the purchase of goods or services when the aggregate dollar amount is greater than $10,000 but less than $100,000 was not followed. Questionable Costs: None reportable Context: Two vendors with purchases over $10,000 and under $100,000 were selected for testing and no price/rate quotes were obtained for one of the vendors. Effect: Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. Cause: The School did not adequately monitor purchases from its vendors to ensure compliance with it policies. Identification as a Repeat Finding: Not a repeat finding Recommendation: All purchases should be monitored by the purchasing and grant management departments to ensure that the purchases are in compliance with the School’s procurement policies.
Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10555 Federal Award Program Year: July 1, 2022 – July 30, 2023 Pass-Through Agency: Arizona Department of Education Pass-Through Number: 07-84-09-001 Type of Finding: Other matter Compliance Requirement: Procurement and Suspension and Debarment Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. Condition: The School’s policy governing procurement requirements for the purchase of goods or services when the aggregate dollar amount is greater than $10,000 but less than $100,000 was not followed. Questionable Costs: None reportable Context: Two vendors with purchases over $10,000 and under $100,000 were selected for testing and no price/rate quotes were obtained for one of the vendors. Effect: Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. Cause: The School did not adequately monitor purchases from its vendors to ensure compliance with it policies. Identification as a Repeat Finding: Not a repeat finding Recommendation: All purchases should be monitored by the purchasing and grant management departments to ensure that the purchases are in compliance with the School’s procurement policies.
Finding 2023-001 - Procurement Federal Agency: U.S. Department of Agriculture Pass-through Agency: Pennsylvania Department of Education Assistance Listing Number: Child Nutrition Cluster – 10.553/10.555 Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: Yes Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The finding was initially identified during the conduct of the audit of the fiscal year ended June 30, 2022, which occurred in October 2022. The District was not able to remedy this finding for the fiscal year ended June 30, 2023 as the contract that the District had with the vendor was for multiple years. The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Finding 2023-001 - Procurement Federal Agency: U.S. Department of Agriculture Pass-through Agency: Pennsylvania Department of Education Assistance Listing Number: Child Nutrition Cluster – 10.553/10.555 Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: Yes Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The finding was initially identified during the conduct of the audit of the fiscal year ended June 30, 2022, which occurred in October 2022. The District was not able to remedy this finding for the fiscal year ended June 30, 2023 as the contract that the District had with the vendor was for multiple years. The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Finding 2023-001 - Procurement Federal Agency: U.S. Department of Agriculture Pass-through Agency: Pennsylvania Department of Education Assistance Listing Number: Child Nutrition Cluster – 10.553/10.555 Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: Yes Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The finding was initially identified during the conduct of the audit of the fiscal year ended June 30, 2022, which occurred in October 2022. The District was not able to remedy this finding for the fiscal year ended June 30, 2023 as the contract that the District had with the vendor was for multiple years. The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Finding 2023-001 - Procurement Federal Agency: U.S. Department of Agriculture Pass-through Agency: Pennsylvania Department of Education Assistance Listing Number: Child Nutrition Cluster – 10.553/10.555 Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: Yes Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The finding was initially identified during the conduct of the audit of the fiscal year ended June 30, 2022, which occurred in October 2022. The District was not able to remedy this finding for the fiscal year ended June 30, 2023 as the contract that the District had with the vendor was for multiple years. The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Finding 2023-001 - Procurement Federal Agency: U.S. Department of Agriculture Pass-through Agency: Pennsylvania Department of Education Assistance Listing Number: Child Nutrition Cluster – 10.553/10.555 Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Additionally, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Furthermore, the District must adhere to the Pennsylvania Public School Code 24 P.S. 1-10, 7-751 and 8-807.1 when procuring goods and services to remain in compliance with commonwealth procurement requirements. Condition: The District did not follow the appropriate procedures to comply with the procurement requirements as established by Uniform Guidance and Pennsylvania Public School Code. Cause and Effect: The District has utilized the same vendor for several years without obtaining annual bids. It did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Guidance and Pennsylvania Public School Code. Questioned Cost: None Context: During testing, it was noted that the District had purchased bakery items from a vendor without following its procurement policy. This was an isolated instance within the scope of the tested population. Identification of Repeat Finding: Yes Recommendation: We recommend that the District ensure it complies with its written procurement policy. The District should document its process and how it complies with the procurement standards. Views of Responsible Officials: The finding was initially identified during the conduct of the audit of the fiscal year ended June 30, 2022, which occurred in October 2022. The District was not able to remedy this finding for the fiscal year ended June 30, 2023 as the contract that the District had with the vendor was for multiple years. The District will establish processes to ensure that the procurement policy is followed when applicable and necessary.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023 U.S. Department of Education Pass-Through Entity – Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: Yes, #2022-003 Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023 U.S. Department of Education Pass-Through Entity – Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: Yes, #2022-003 Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023 U.S. Department of Education Pass-Through Entity – Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: Yes, #2022-003 Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023 U.S. Department of Education Pass-Through Entity – Pennsylvania Department of Education Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320. Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy. Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance. Identification of Repeat Finding: Yes, #2022-003 Questioned Costs: None Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents. Management Response: See Corrective Action Plan on pages 84 - 85.
Identification of Federal Program 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria 2 CFR 200.320 Methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and 200.317, 200.318, and 200.319 for formal methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.320(b) Formal procurement methods. When the value of the procurement for property or services exceeds the simplified acquisition thresholf, formal procurement methods are required. Formal procurement methods require either sealed bids to be publicly solicited or requests for proposal publicized. Non-competitive procurement are only allowed if the purchase is under the micro-purchase threshold, if the item is only available from a single source, if public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation, if the Federal awarding agency or pass through agency expressly authorizes a non-competitive procurement, or if after solicitiation of a number of sources, competition is deemed inadequate. Condition The County did not follow formal procurement procedures related to the purchase of jail camera system. Cause The County followed its internal procurement policies which are less restrictive than formal procurement processes as required under 2 CFR 200.320. Potential Effect Open competition was not insured. Questioned Costs None Context The County followed their modified procurement procedure (PPCO 15.140(1) which allows for direct solicitation of bids from vendors that work with existing technology infrastructure already in place in the County in an effort to reduce cost and waste. As a result, formal procurement processes as required were not followed. Identification of a repeat finding, if applicable This is a new finding for the County Recommendations Formal procurement processes should be followed for all Federal award purchases that exceed the simplified acquisition threshold. Views of Responsible Officials The County agrees with the finding and will develop a corrective action plan.
Identification of Federal Program 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria 2 CFR 200.320 Methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and 200.317, 200.318, and 200.319 for formal methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.320(b) Formal procurement methods. When the value of the procurement for property or services exceeds the simplified acquisition thresholf, formal procurement methods are required. Formal procurement methods require either sealed bids to be publicly solicited or requests for proposal publicized. Non-competitive procurement are only allowed if the purchase is under the micro-purchase threshold, if the item is only available from a single source, if public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation, if the Federal awarding agency or pass through agency expressly authorizes a non-competitive procurement, or if after solicitiation of a number of sources, competition is deemed inadequate. Condition The County did not follow formal procurement procedures related to the purchase of jail camera system. Cause The County followed its internal procurement policies which are less restrictive than formal procurement processes as required under 2 CFR 200.320. Potential Effect Open competition was not insured. Questioned Costs None Context The County followed their modified procurement procedure (PPCO 15.140(1) which allows for direct solicitation of bids from vendors that work with existing technology infrastructure already in place in the County in an effort to reduce cost and waste. As a result, formal procurement processes as required were not followed. Identification of a repeat finding, if applicable This is a new finding for the County Recommendations Formal procurement processes should be followed for all Federal award purchases that exceed the simplified acquisition threshold. Views of Responsible Officials The County agrees with the finding and will develop a corrective action plan.
Procurement and Suspension and Debarment Award Information: Grantor: U.S. Department of Transportation Assistance Listing Number: 20.509, Formula Grants for Rural Areas and Tribal Transit Program. Criteria Non-federal entities other than states, including those operating federal programs as sub-recipients of states, must follow procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procedures which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. This includes meeting the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors and maintaining records to document history of procurements. This also includes conducting procurement transactions in a manner providing full and open competition in accordance with 2 CFR section 200.319 including the use of micro-purchases and small purchase methods for procurements that meet the applicable criteria under 2 CFR section 200.320. Condition The District does not have documented procurement procedures in accordance with the procurement standards set out at 2 CFR sections 200.318 through 200.326. Cause Previous management did not implement and previous District policies did not include documentation of procurement procedures in accordance with federal standards. New management is in place and have commenced an ongoing project to summarize accounting related activities into an accounting procedures manual, this includes the required procurement procedures. Effect The District does not have documented procurement procedures as required by federal standards. Not having the required procurement procedures in place could lead to awarding contracts and making purchases without adequate competition. Questioned Costs No questioned costs. Recommendation We recommend that the District formally document a procurement policy in accordance with federal standards to include all general requirements such as oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, maintaining records to document history of procurements and conducting procurement transactions in a manner providing full and open competition. Management Response and Planned Corrective Action Following these findings are management’s view and corrective action plan.
Procurement and Suspension and Debarment Award Information: Grantor: U.S. Department of Transportation Assistance Listing Number: 20.509, Formula Grants for Rural Areas and Tribal Transit Program. Criteria Non-federal entities other than states, including those operating federal programs as sub-recipients of states, must follow procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procedures which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. This includes meeting the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors and maintaining records to document history of procurements. This also includes conducting procurement transactions in a manner providing full and open competition in accordance with 2 CFR section 200.319 including the use of micro-purchases and small purchase methods for procurements that meet the applicable criteria under 2 CFR section 200.320. Condition The District does not have documented procurement procedures in accordance with the procurement standards set out at 2 CFR sections 200.318 through 200.326. Cause Previous management did not implement and previous District policies did not include documentation of procurement procedures in accordance with federal standards. New management is in place and have commenced an ongoing project to summarize accounting related activities into an accounting procedures manual, this includes the required procurement procedures. Effect The District does not have documented procurement procedures as required by federal standards. Not having the required procurement procedures in place could lead to awarding contracts and making purchases without adequate competition. Questioned Costs No questioned costs. Recommendation We recommend that the District formally document a procurement policy in accordance with federal standards to include all general requirements such as oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, maintaining records to document history of procurements and conducting procurement transactions in a manner providing full and open competition. Management Response and Planned Corrective Action Following these findings are management’s view and corrective action plan.
2023-001 – Uniform Guidance Procurement Standards Criteria: One of the more significant provisions of the Uniform Guidance that affects the Town is the procurement standards under 2 CFR sections 200.318 through 200.326. Under the procurement standards, the Town is required to have a documented purchasing policy, which at a minimum, incorporates the provisions of the Uniform Guidance. Statement of Condition: The Office of Management and Budget (OMB) revised regulations applicable to federally funded programs. The regulations are contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance replaced OMB Circulars A-133, A-87, and A-110 and incorporates requirements for grant recipients. The Uniform Guidance includes not only protocols for program management and administration, but also updates compliance regulations for federal awards. Cause: The Town had not adopted a procurement policy that covered all aspects required by the Uniform Guidance. However, during our testing of procurement over federal expenditures, we did not notate any violations of the Uniform Guidance procurement standards. Effect: Items required by the Uniform Guidance procurement standards were not addressed in the policy followed by the Town during the fiscal year. Recommendation: We recommend that management review the applicable provisions of the Uniform Guidance procurement standards and update the Town’s procurement policy appropriately. This would include adding any missing components to the Town’s current procurement policy and updating definitions of types of procurement, i.e. micro-purchases, small purchases, and small acquisition threshold, to match the language used in the Uniform Guidance procurement standards.
2023-003: Written Debarred, Suspended Vendors & Federal Standards of Conflict Findings Prior Year Findings: Yes, 2022-004 Department Agency: Environmental Protection Agency State Department: Wyoming State Loan & Investment Board Office of State Lands & Investments Assistance Listing Number: ALN # 15.252 Compliance Area: Procurement & Suspension & Debarment (I) Type of Finding: Significant Deficiency Questioned Costs: None Criteria: The Town of Dayton should have written standards of conduct in place to verify any entity (vendor) with which the Town spends Federal expenditures of conducts business transactions be not debarred, suspended, or otherwise excluded per 2 CFR 200.318(h) and 2 CFR 180. The written standard should address conduct covering conflicts of interest governing the performance of its employees and contractors engaged in the selection, award, and administration of contracts (Uniform Guidance Section 200.318 and 45 CFR sections 52.203-13 and 52.203-16). Condition: The Town of Dayton did not have written controls in place to ensure that vendors were not suspended or debarred or included on the list of vendors prior to entering into a contract with the Town. The written standard of conduct covering conflicts of interest and governing the performance of its employees and contractors must be documented when engaged in the selection, award and administration of Federal grant contracts. Cause and Effect: The Town of Dayton due to large influx of Federal expenditures. There was not a control in place to ensure that vendors or contractors the Town entered into contracts with were not suspended or debarred before contracts were executed. Without a reliable control in place to ensure compliance, the Town of Dayton could enter into a contract with a suspended or debarred party and have a control of interest with the Federal written contracted parties. Repeat Finding: Yes Recommendation: We recommend that the Town of Dayton put written internal controls in place such as using a checklist to ensure Federal funds that pay contractors are not suspended or debarred and should consider the Town of Dayton adopt a policy on procurement for debarment. The town needs to adopt a written policy when spending Federal funds, to ensure no conflict of interests exist. Response: Please see the last page of this report for he Town's repsonse to this finding.
Department of Education, Passed through North Dakota Department of Public Instruction Federal Financial Assistance Listing/CFDA Number 84.027/84.173 Special Education Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition – In our testing of procurement, suspension and debarment it was identified that the District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Cause – Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect – A lack of documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities. Questioned Costs – None reported Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – Yes, prior year finding 2022-004 Recommendation – We recommend that management establish a written policy that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials – There is no disagreement with the audit finding.
Department of Education, Passed through North Dakota Department of Public Instruction Federal Financial Assistance Listing/CFDA Number 84.027/84.173 Special Education Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition – In our testing of procurement, suspension and debarment it was identified that the District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Cause – Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect – A lack of documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities. Questioned Costs – None reported Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – Yes, prior year finding 2022-004 Recommendation – We recommend that management establish a written policy that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials – There is no disagreement with the audit finding.
Department of Education, Passed through North Dakota Department of Public Instruction Federal Financial Assistance Listing/CFDA Number 84.027/84.173 Special Education Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition – In our testing of procurement, suspension and debarment it was identified that the District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Cause – Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect – A lack of documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities. Questioned Costs – None reported Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – Yes, prior year finding 2022-004 Recommendation – We recommend that management establish a written policy that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials – There is no disagreement with the audit finding.
Department of Education, Passed through North Dakota Department of Public Instruction Federal Financial Assistance Listing/CFDA Number 84.027/84.173 Special Education Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition – In our testing of procurement, suspension and debarment it was identified that the District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Cause – Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect – A lack of documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities. Questioned Costs – None reported Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – Yes, prior year finding 2022-004 Recommendation – We recommend that management establish a written policy that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials – There is no disagreement with the audit finding.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.